FSVP for Indonesian Seafood: The 2025 Buyer Pack

An inspection‑ready, action‑first FSVP checklist tailored to Indonesian shrimp. Exactly what FDA expects to see in 2025, how often to verify, what to request from your processor, and how to review HACCP for antibiotics, Vibrio, sulfites and RTE controls.

If you import Indonesian shrimp into the U.S., you don’t want a generic FSVP binder. You want an inspection‑ready pack that makes FDA’s review painless. After building dozens of files with buyers and auditors, here’s the exact 2025 Buyer Pack we recommend. It maps to the FSVP rule and the real shrimp hazards we all wrestle with: antibiotic residues, Vibrio and Salmonella, sulfites, and post‑cook contamination.

The 2025 Buyer Pack: what FDA actually expects to see

Here’s the short list we’ve seen FDA ask for during FSVP inspections and remote record reviews. Build it once and keep it warm with current records.

1. Your FSVP framework

• Importer identification and DUNS. Name, address, DUNS matching your customs entry.
• FSVP Qualified Individual designation. Name, qualifications, and what they did or oversaw.
• Product‑supplier matrix. Which items you import, from which establishments, and who controls hazards.

2. Hazard analysis for each shrimp SKU

• Written hazard analysis. Identify reasonably foreseeable hazards. For shrimp that’s typically antibiotics, Vibrio spp., Salmonella, sulfites, allergens, metal, and for cooked shrimp, Listeria and post‑cook contamination.
• Decision on who controls each hazard. Supplier, you, or a subsequent processor. Justify with your distribution and end use.

3. Supplier evaluation and approval

• Indonesian processor dossier. HACCP plan and hazard analysis, process flow, SSOPs, training, water/ice micro results, equipment calibration, pest, glass/metal controls.
• Evidence of implementation. At least one full month of monitoring records aligned to their HACCP CCPs. For cooked shrimp: cook logs, cooling logs, metal detection, and environmental swab results if the product is RTE.
• Third‑party audits. GFSI benchmarked audit reports are useful if they explicitly cover seafood hazards and applicable regulation. We still pair them with HACCP records.
• BKIPM Health Certificate samples. Shows government oversight and lot health status, but it’s support, not a substitute for FSVP verification.

4. Verification activities and results

• Your chosen verification methods with rationale. Onsite audit, sampling/testing, and/or records review. Explain why the frequency fits the risk.
• Test COAs you relied on. Antibiotics, pathogens, sulfites. Keep lab scope, methods, LOQs, and sample traceability.
• Onsite audit reports or structured remote assessments. Ensure the auditor is qualified for seafood and RTE if applicable.

5. Lot files and traceability

• Lot‑specific documents. COAs, packing list, temperature records, labels, BKIPM health certificate for the lot, and corrective actions when needed.
• SIMP records if applicable to your shipments. These don’t replace FSVP but strengthen traceability.

6. Reanalysis and corrections

• Periodic reanalysis. Annual or when anything changes. Capture supplier changes, spec changes, or regulatory updates.
• Corrective action records. What failed, what you did, how you verified effectiveness.

We’ve found that when these six buckets are clear and current, inspections are short and cordial. But there’s more to consider.

Is an Indonesian HACCP certificate enough?

No. A HACCP certificate helps you evaluate supplier competency, but FSVP asks for your own hazard analysis, your supplier evaluation, and your verification activities. FDA wants to see you made a risk‑based call and followed through with records.

Practical takeaway: request the full HACCP plan and a recent implementation set. For cooked shrimp, ask for one month of cook and cooling logs, metal detector checks, and any Listeria environmental monitoring results. For raw frozen shrimp, focus on sanitation, sulfite controls, and residue‑testing programs.

How often should you verify a shrimp supplier under FSVP?

Risk drives frequency. In our experience, FDA scrutiny on antibiotics and RTE controls has increased over the past year, including more remote document requests.

A workable frequency matrix for 2025:

• New supplier, any shrimp: enhanced verification for first 3–5 lots. Every‑lot antibiotics COA plus micro COA, then step down if results are clean.
• Cooked RTE shrimp: annual onsite audit by a qualified auditor or an equivalent GFSI audit that explicitly covers RTE environmental controls. Maintain periodic testing for Salmonella and Listeria in product or environment.
• Raw frozen shrimp for further cooking: quarterly records review and periodic antibiotics testing if the supplier has a robust, validated residue program. Monthly micro COAs at startup, moving to quarterly if stable.
• Any loss of control or regulatory finding: escalate to every‑lot testing and an immediate focused audit.

Document the why, not just the when. Tie your frequency to hazards and supplier performance.

Do you need antibiotic residue COAs for every lot?

FSVP doesn’t mandate lot‑by‑lot testing if other verification is robust. But with ongoing import alerts on unapproved aquaculture drugs, most importers keep every‑lot or high‑frequency testing at the start and then step down.

What’s worked for buyers:

• New farmed vannamei or black tiger source: test each lot for chloramphenicol and nitrofuran metabolites (AOZ, AMOZ, SEM, AHD) for the first 5 clean lots. Keep fluoroquinolones on your screen if you have historical regional risk.
• Stable, approved supplier with government and private monitoring: shift to 1 in 3 lots or monthly, documented in your verification procedure.
• Wild shrimp: lower antibiotic risk. Verify once per quarter or per season, and add targeted tests when supply chains change.

Make sure your lab methods meet or beat FDA detection limits and include LOQs on the COA. If a COA lacks method and LOQ, we send it back.

What should you look for when reviewing an Indonesian HACCP plan?

We like to do a quick three‑pass review.

• Pass 1. Does the hazard analysis explicitly call out your products? Raw versus cooked shrimp aren’t interchangeable. Cooked needs validated time/temperature, controlled cooling, and post‑cook hygiene. Raw needs sulfite control, sanitation, and storage temperature.
• Pass 2. Do CCPs match the hazards? For sulfites, see receiving and processing limits plus verification testing. For RTE, look for Listeria environmental monitoring with defined sites, frequency, and corrective actions.
• Pass 3. Implementation evidence. Are there real logs matching the plan for the month you sampled? Are deviations documented and closed?

If anything feels boilerplate, ask the plant to walk you through a recent deviation and correction. The way they explain it tells you a lot about day‑to‑day control.

Vibrio and Salmonella: what’s reasonable in your file?

For raw frozen shrimp, you should show how Vibrio and Salmonella are being addressed. Many buyers use supplier micro programs with acceptance criteria of Salmonella not detected in 25 g, and Vibrio testing either routine or targeted by water temperature season. For cooked RTE shrimp, your file should emphasize validated cooking and post‑cook controls, plus Salmonella not detected in finished product. We also like to see periodic environmental swabs for Listeria on RTE lines.

Document seasonality if your supplier sources from multiple ponds or regions. Warmer water periods correlate with higher Vibrio counts, which justifies increased testing frequency.

Can SIMP records double as FSVP documentation?

SIMP strengthens traceability, but it doesn’t replace FSVP. Use your SIMP harvest, vessel, farm, and transshipment data to connect lots, but you still need the hazard analysis, supplier evaluation, and verification results. That said, FDA likes seeing a tight SIMP chain. It gives confidence your COAs and certificates belong to the lot on entry.

Who can serve as your FSVP Qualified Individual for shrimp?

FSVP requires a qualified individual with education, training, or experience to perform or oversee the activities. That can be your in‑house food safety lead or an external consultant. Seafood experience matters. If your QI has Preventive Controls training but no seafood background, pair them with a seafood HACCP‑trained reviewer and document the combined qualifications.

The inspection‑ready document list for Indonesian shrimp suppliers

Use this as your request template when onboarding or refreshing a supplier. We keep it to two bundles: company‑level and lot‑level.

Company‑level (annual, or when changed)

• Valid HACCP plan and hazard analysis for your exact products and formats.
• Process flow, SSOPs, allergen controls, glass/metal policy, calibration.
• For cooked RTE shrimp: thermal validation, cooling validation, environmental monitoring program and last 3 months of trend summaries.
• Antibiotic residue program. Sampling plan, analytes, methods, LOQs, and recent summary results.
• Sulfite control SOP and recent verification tests.
• Potable water and ice microbiology reports.
• Most recent GFSI audit report and closure of nonconformities, if available.
• BKIPM health certificate template and license/registration details.

Lot‑level (per shipment)

• COA covering antibiotics panel appropriate to risk and your frequency plan.
• Micro COA. Salmonella n.d. in 25 g. Vibrio program per your spec. For cooked, include finished product Salmonella and post‑cook hygiene controls.
• Sulfite result where applicable. Allergen label review for cooked and breaded products.
• Packing list, label, and temperature records.
• BKIPM health certificate for the lot.
• Any deviations and corrective actions.

Need a sanity check on your current pack for Indonesian suppliers? You can Contact us on whatsapp and we’ll point out the gaps we see FDA flag most often.

Common mistakes we still see (and easy fixes)

• Treating a HACCP certificate like a silver bullet. Fix: ask for the plan and matching records. Review against your hazards.
• Testing without traceability. Fix: make sure sample IDs map to production codes and container numbers on entry.
• Relying only on quarterly COAs for new suppliers. Fix: start every‑lot, then step down with a documented rationale.
• Skipping RTE environmental monitoring in the review. Fix: for cooked shrimp, confirm swab sites, frequency, and corrective actions in the last three months.
• Unclear verification frequency. Fix: put the schedule and the why in a one‑page FSVP verification summary. Inspectors love clarity.

Where our products fit if you need a spec‑aligned source

If you need Indonesian shrimp with an FSVP‑friendly documentation flow, our Frozen Shrimp (Black Tiger, Vannamei & Wild Caught) program includes residue COAs, micro COAs, and BKIPM certificates aligned to lot codes. We also support mixed seafood programs where similar verification applies across white‑flesh species. If you’re building category coverage, you can View our products to see how we standardize specs and lot files across items like snapper, grouper, and mahi.

Bottom line

An FSVP file that’s inspection‑ready isn’t complicated. It’s complete. Map hazards to controls, pick a verification cadence you can defend, and keep lot files tight. In our experience, when you can explain your why in two minutes and produce matching records, FDA moves on quickly. And that’s the goal.